The Good Faith Exception to the Exclusionary Rule cases
In United States v. Leon (1984) 468 U.S. 897, the high court recognized a good faith exception to the exclusionary rule when it held that where an officer acts in objectively reasonable reliance on a search warrant issued by a detached and neutral magistrate that is later found to be unsupported by probable cause, the exclusion's deterrent effect is insufficient to warrant the exclusionary rule's application. (Leon, supra, 468 U.S. at pp. 920-921.)
The court concluded the potential behavioral effect on judicial officers is insufficient to justify exclusion, for the following three reasons:
"First, the exclusionary rule is designed to deter police misconduct rather than to punish the errors of judges and magistrates. Second, there exists no evidence suggesting that judges and magistrates are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion. Third, and most important, we discern no basis, . . . for believing that exclusion of evidence seized pursuant to a warrant will have a significant deterrent effect on the issuing judge or magistrate." (Id. at p. 916.)
The United States Supreme Court subsequently extended the principles stated in Leon to situations where (1) an officer acts in objectively reasonable reliance on a statute authorizing a warrantless search, even though the statute is later found to violate the Fourth Amendment (Illinois v. Krull (1987) 480 U.S. 340 at p. 342); and (2) where police acted in objectively reasonable reliance on erroneous computer records indicating the existence of an arrest warrant, when the source of the error may have been a court clerk rather than law enforcement (Evans, supra, 514 U.S. at pp. 4-5).
In Arizona v. Evans (1995) 514 U.S. 1, a police officer arrested the defendant following a traffic stop when the defendant's name appeared on the police computer as having an outstanding arrest warrant. During the ensuing search, marijuana was found in the defendant's car. The police later learned the arrest warrant had been quashed 17 days before the arrest. The defendant moved to suppress the evidence, arguing the good faith exception did not apply because police error, not judicial error, caused the invalid arrest. (Evans, supra, 514 U.S. at p. 4.) Testimony at the suppression hearing indicated a court clerk, rather than a records clerk in the sheriff's office, may have been responsible for the error in the police computer by failing to inform the sheriff's office the warrant had been quashed. (Id. at p. 5.)
Applying the United States v. Leon (1984) 468 U.S. 897 framework, the court held that if a court employee was responsible for the erroneous information, exclusion of the evidence would not be warranted, explaining:
"First . . . the exclusionary rule was historically designed as a means of deterring police misconduct, not mistakes by court employees. Second, respondent offers no evidence that court employees are inclined to ignore or subvert the Fourth Amendment or that lawlessness among these actors requires application of the extreme sanction of exclusion. . . . Finally, and most important, there is no basis for believing that application of the exclusionary rule in these circumstances will have a significant effect on court employees responsible for informing the police that a warrant has been quashed. Because court clerks are not adjuncts to the law enforcement team engaged in the often competitive enterprise of ferreting out crime, they have no stake in the outcome of particular criminal prosecutions. The threat of exclusion of evidence could not be expected to deter such individuals from failing to inform police officials that a warrant had been quashed." (Evans, supra, 514 U.S. at pp. 14-15.)